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20 Za 22 23 24 25 Case 1:15-cv-07433-LAP Document 1332-10 Filed 01/08/24 Page 58 of 64 57 H2G8GIUC does is, since we can't figure out what it means, what we will try to do is just prove that she was sexually abused. In the words of Ms. McCawley, I am going to prove that my client was sexually abused and trafficked. Well, that doesn't satisfy your burden of proving defamation. The fact that the plaintiff was sexually abused and trafficked? No. To use Ms. McCawley's words, there is a plethora of allegations. Take a look at Exhibits A and B. Take a look at the CVRA joinder motion. Talk about plethora. Judge, this plaintiff has said at least 100 different things in all these news articles, the original allegations, and then another couple of dozen in the CVRA joinder motion. Well, which of these allegations is the plaintiff going to prove, if true, in order to show that my client's statement from January 2015 is false? I think what we hear from Ms. McCawley is we are not going to do that. Well, Judge, if we are not going to do that, can we please have summary judgment because they can't prove their case. You can't prove your case by showing that Ms. Giuffre was sexually abused and trafficked. On the republication issue, Judge, Ms. McCawley says there is no better evidence about the authorization and control of republication other than the words in Mr. Gow's e-mail, "please find this quotable statement," on behalf of Ms. Maxwell. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300